Facts
- Lake Iamonia is a navigable lake in Leon County, Florida, containing several privately owned islands.
- The lake is shallow and heavily vegetated, making travel by ordinary boat difficult; for some islands, airboats were the only practical means of access.
- A 1977 drawdown further reduced water levels, worsening access conditions.
- A special law authorized the Florida Game and Fresh Water Fish Commission to regulate motorboat use on Lake Iamonia.
- The Commission adopted a rule absolutely prohibiting motorboats, including airboats, on the lake during duck hunting season.
- Island owners alleged the seasonal total ban effectively denied them reasonable ingress and egress to their property and unreasonably interfered with their riparian right of access.
Issues
- Whether the statute authorizing motorboat regulation and the implementing rule imposing a total motorboat ban during duck season were unconstitutional as applied to island owners who required airboats as the only practical means of access.
- Whether the Commission’s exercise of police power unreasonably and arbitrarily interfered with the island owners’ riparian right of access to their property.
Decision
- The Florida Supreme Court affirmed the trial court.
- The statute and rule were constitutional on their face and valid as applied to the general public.
- As applied to island owners whose only practical access required airboats, the total seasonal motorboat ban was unconstitutional because it unreasonably and arbitrarily interfered with their access rights.
- The relief was limited to preventing enforcement of the blanket ban in a manner that denied island owners reasonable ingress and egress.
Legal Principles
- Riparian owners on navigable waters possess a protected right of reasonable access between their property and the waterway.
- The state may regulate use of navigable waters under the police power, including for wildlife management and public safety.
- Even a generally valid regulation may be unconstitutional as applied when it unreasonably and arbitrarily burdens a protected property right.
- A boating restriction that eliminates the only practical means of ingress and egress to riparian or island property exceeds permissible regulation as applied to those owners and requires accommodation for reasonable access.
Conclusion
The court upheld the Commission’s general authority to restrict motorboats on Lake Iamonia during duck season but held that a total ban could not be enforced against island owners when, given lake conditions, it cut off their only practical means of reaching their property and thus unreasonably violated their riparian right of access.